Sanctions Guidance for Insolvency Practitioners


Once a person or entity has been sanctioned under EU financial sanctions, there is a legal obligation not to transfer funds or make funds or economic resources available, directly, or indirectly, to that person or entity.

It is essential that Insolvency Practitioners recognise that they have increased exposure to potential risks including:

  a. Falling foul of sanctions through the holding of funds, assets, or other economic resources on behalf of individuals or organisations on sanctions lists.

  b. Money laundering as individuals and business may seek to evade these respective sanctions regimes.

  c. Clients falling within the definition of Politically Exposed Persons (“PEP”).

  d. Consideration should also be given to individuals and entities that may be owned or controlled by a sanctions target. Those entities may not be designated in their own right, so their names may not appear on the consolidated list. However, those entities are similarly subject to financial sanctions.

CCAB-I has issued a help sheet for Insolvency Practitioners on the impact of the Sanctions. For details click here.